Protean Training Services Ltd Anti-Bribery and Anti-Corruption Policy
Our references to “our company” or “we” means Protean Training Services Ltd.
Who we are.
Protean Training Services Ltd provides training and facilitation services. Our company number is 11921074 and our registered address is: The Stables, Money’s Farm, Bottle Lane, Mattingly, Hampshire RG27 8LJ.
Protean Training Services Ltd are registered with the Information Commissioners Officer.
The following outlines Protean Training Services Anti-Corruption and Anti-Bribery policy.
Our Core Values guide everything we do.
In line with our Core Values, we are committed to acting with honesty and integrity in all our activities. We are honest, ethical, open and fair.
We comply with all laws relevant to countering bribery and corruption in all jurisdictions in which we operate. For example, the UK Bribery Act 2018.
We have a culture of ethical behaviour and expect our employees, contractors, associates and suppliers to act with honesty and integrity in all their dealings related to our business.
We will not tolerate any corrupt practices and will report any such matters to the appropriate legal authority.
This policy applies to all persons working for us, including directors, employees, consultants, contractors, associates, partners, agents, suppliers or any other persons associated with us, all of whom are expected to know this policy, comply with its terms and keep themselves up to date with any changes. This policy does not form part of any contract of employment and we may amend it at any time.
We ask and encourage everyone to be vigilant at all times and report any suspicions you may have.
Anti-Corruption and Anti-Bribery.
Hospitality & Gifts must be:
- Proportionate and appropriate.
- Transparent and declared.
- Approved in advance (where appropriate)
You must always avoid accepting or offering any hospitality or gift which does not meet the above criteria. All hospitality and gifts must be transparent and declared to our Compliance Officer and where appropriate, approved in advance. If you are unsure if any hospitality or gift complies with this policy, you must seek advice and guidance from the Compliance Officer.
Entertaining or being entertained by clients, potential clients, suppliers or any other contacts is not in itself prohibited. However, it must be proportionate and appropriate and given or accepted in the context of our business.
Lavish entertainment is prohibited as is repeated entertainment of the same client or repeated entertainment by a third part for a Protean Training Services director, employee, consultant, contractor, associate, partner, agent, supplier or any other persons associated with us.
Gifts should not be offered or accepted unless it is clearly not a potential factor in any business decision. Gifts should be proportionate and appropriate. The local customs for gifts and hospitality varies and in some Countries the giving of gifts is expected as part of the business culture. Advice should always be obtained from the Compliance Officer. No extravagant gifts should be offered. If any valuable gifts are offered to you, they must be reported to the Compliance Officer who will decide how it should be dealt with. A valuable gift is anything worth more than £100.
Cash & Financial Incentives.
It is prohibited to solicit or accept any cash or financial benefit or assistance from any third party with whom our Company may have a business connection. It is also prohibited to make any cash gifts or payments to third parties with whom you deal in relation to our Company’s business.
It is not acceptable to make a facilitation payment to any Government or other official or any other third party in order to speed up an official procedure or achieve an advantage through the payment when no such payment is officially required. If in doubt whether a payment being requested is legitimate, you should seek advice and guidance from the Compliance Officer. Any request for a facilitation payment must be reported to the Compliance Officer or Head of Practice. Any payment to a Government or other public official in the UK, or elsewhere should only be made if it is legally justified, authorised in advance by the Compliance Officer and an official receipt obtained.
Government and Other Officials.
You must be careful when dealing with Government or public officials in relation to contracts that our Company is negotiating with any Governmental or other official body, whether in the UK or elsewhere. Any expenses involving an official should be cleared and agreed with both with the Compliance Officer and with the body for which that official works.
It is prohibited to have any dealing with a third party with whom our Company has a business connection, whereby you or a friend or relative might gain an advantage in return for some business advantage for that third party. Any offer of personal benefit must be reported to the Compliance Officer. Furthermore, if our Company representative suspects that a personal benefit may result from the course of legitimate business, this must be reported to the Compliance Officer, for the avoidance of doubt, before that business takes place.
Donations to Political Parties.
The Company does not make donations to any political party.
All Company donations to registered charities must be approved in advance by a Company Director and made via official Finance channels. Private donations to registered charities by any employee, consultant, contractor, associate, partner, agent, supplier or any other persons associated with us, are not the concern of the Company and do not have to be reported. Any Company fund raising activities need approval from a Company Director.
The Company Director has a clear commitment to our policy and has overall responsibility for ensuring this policy complies with our legal and ethical obligations and will monitor compliance to this policy on a regular basis.
The Company has a Compliance Officer, Martin Edwards, who is the Company Director and who will report regularly to the Board. The Compliance Officer is the point of contact for advice and guidance and to whom any suspicion of bribery or any other concern relating to unlawful activity should be reported.
Consultants, Contractors, Associates, Partners, Agents, Suppliers, Business Partners & Third Parties.
It is also the responsibility of the Company Director to bring this policy to the attention of our employees, consultants, contractors, associates, partners, agents, suppliers or any other business partners. Outside parties who provide services to the Company or act on our behalf should be made aware of this policy be asked to confirm they will comply with it in their dealings on behalf of our Company.
Each employee is expected to conduct business with honesty and integrity. They should be vigilant against any conduct that is or appears to be corrupt in any respect. They should report any concerns to the Compliance Officer.
The Compliance Officer will maintain appropriate procedures to ensure all relevant transactions, including entertainment and hospitality costs are recorded and any abnormal expenses identified and investigated.
Whenever our Company considers a new venture with another organisation or individual, a risk assessment and due diligence may be undertaken where the Director considers it necessary on the prospective business partner. The Director will consider the results before sanctioning any formal relationship. Once risks have been identified and assessed, the Director will decide on how best to proceed and protect our interests and comply with the relevant legislation. The risk assessment will be used to determine appropriate controls.
Before entering into negotiations with third parties and before any letter of intent, commitment or contract is made with a third party, appropriate due diligence on that third party and the foreseeable related transactions will, where necessary, be undertaken. Visits to the other party’s premises and investigation of their business may be required as a preliminary to any contractual commitment. Any such checks will be coordinated by the Compliance Officer if required. As for any contract, the terms will always require approval in accordance with existing Company procedures and no binding commitment can be made before this is given. The terms of all contracts should contain the usual protection for our Company and should include a provision that obliges the other party to comply with the Bribery Act 2010, Criminal Justice (Corruption Offences Act) 2018 or other applicable law and not to do or permit anything that might put the Company in breach any applicable legislation.
Communication and Training.
Within our Company, all employees, consultants, contractors and associates will be made aware of this policy and will receive further training on it as required. The Compliance Officer has responsibility for this. All new employees, consultants, contractors and associates, will receive a copy of this policy as part of their onboarding process. If you need advice relating to any issues within this policy, you should seek advice and guidance from the Compliance Officer.
Monitoring & Review.
The implementation of this policy will be monitored by the Compliance Officer. All cases involving corruption or bribery, or attempted bribery will be considered by the Company Director. This policy will be kept under review and adjusted to meet any new legislation or Government guidelines. Any such changes must be approved by the Company Director.
It is the responsibility of the employee, consultant, contractor, associate, partner, agent, supplier or any other to comply with the Company policy. Breaches in the standards required by this policy will be addressed by the Company disciplinary procedure. Any breach of the policy will be treated seriously and could constitute gross misconduct by an employee resulting in dismissal or termination of a contract with any consultant, contractor, associate, partner, agent, supplier or any other.
There are no exceptions.